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TSG Privacy Policy

The Transaction Services Group (TSG) takes privacy and data protection issues seriously. We have designed this TSG Privacy Policy to explain how we handle personally-identifiable information.

The following statements relate to the collection of data, information security and privacy standards applicable to all users of the TSG Website (TSG Site). For the purpose of this policy, TSG, weand usrefer to the Transaction Service Group of Companies. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. See “Region-Specific Information” below. Please read this policy carefully.

TSG provides revenue management solutions through a number a number of leading recurring billing solution providers around the world. As a part of providing these services, we routinely collect and retain personal information about our customers and the third parties with whom our customers do business. For our customers, information about disclosures, transfers and other processing of personal information as part of our payment processing function is set out in the documentation provided to them at the onboarding stage and is outside of the scope of this policy, which relates only to information we obtain through the TSG Site.

WHO ARE WE?

TSG has a global presence with core Group companies in different territories:

New Zealand

Debitsuccess Limited (Company no.620358) is a company incorporated in New Zealand, with its registered office in Auckland.

Paysmart NZ Limited (Company no.5691727) is a company incorporated in New Zealand, with its registered office in Auckland.

Clubware Limited (Company no. 874046) is a company incorporated in New Zealand, with its registered office in Auckland.

Australia

Debitsuccess Pty Limited (ACN 095 551 581) is a company incorporated in Australia, with its registered office in Brisbane, Queensland 4000.

Paysmart Pty Limited (CAN 117 597 010) is a company incorporated in Australia, with its registered office in Brisbane, Queensland 4000.

Clubware Pty Limited (ACN 115 985 905) is a company incorporated in Australia, with its registered office in Brisbane, Queensland 4000.

QK Technologies Pty Limited (ACN 119 998 122) is a company incorporated in Australia, with its registered office in Brisbane, Queensland 4000.

Links Modular Solutions Pty Limited (ACN 104 429 923) is a company incorporated in Australia, with its registered office in Brisbane, Queensland 4000.

United Kingdom and Europe

Transaction Services Group Limited (UK Company no.9766556) is a company incorporated in the United Kingdom, with its registered office at Rockwood House, Perrymount Road, Haywards Heath, West Sussex, RH16 3TW.

Harlands Group Limited (UK Company no.2982917) is a company incorporated in the United Kingdom, with its registered office at Rockwood House, Perrymount Road, Haywards Heath, West Sussex, RH16 3TW.

Debit Finance Collections PLC. (UK Company no.3422873) is a company incorporated in the United Kingdom, with its registered office at 16 Davy Avenue, Knowlhill, Milton Keynes, Buckinghamshire, MK5 8PL.

USA

Transaction Services Group (USA) Incorporated (Colorado 20161766142) is a company incorporated the United States, with its registered office at 2 North Central Avenue, #1800 Phoenix, AZ 85004.

Debitsuccess (USA) Incorporated (Colorado 20161748022) is a company incorporated in the United States, with its registered office at 2 North Central Avenue, #1800 Phoenix, AZ 85004.

PERSONAL INFORMATION WE OBTAIN

In the course of providing revenue management solutions for its clients, TSG (or any one of its Group companies), may process:

Business contacts, including names, phone numbers and email addresses.

If you would like to unsubscribe from our mailing lists, please either use the unsubscribe feature within the mail, or, send a request to unsubscribe to the relevant email address set out in ‘Region-specific Information’ section below.

HOW WE USE PERONAL INFORMATION

We, or one of our Group Companies, may use your personal information for a number of reasons including the following:

To set up and administer your registration, and use of, the log in facility available on the TSG Site;

For record-keeping and administration purposes;

To improve and personalise your experience when you use the TSG Sitep;

To make improvements to our products and services;

To contact you regarding any enquiry you make;

For statistical analysis;

To contact you by email, telephone or post including, if you have consented, to share newsletters or other updates, communications and/or publications;

TSG is a global business headquartered in Auckland, New Zealand, with a number of Group companies in various territories throughout the world. Your personal information may, with your consent (if required by law) be disclosed to recipients located outside of your country, including by one TSG company to another TSG company as is required to help us run our business. Disclosure may also occur to service providers engaged to perform functions on our behalf or to provide services to us, including (without limitation) legal, accounting, audit, consulting and other professional service providers. Some of our services may be provided by organizations with which TSG has a contractual relationship (including subcontractors), and, as a consequence, your personal information may be disclosed to them. We take steps aimed at ensuring that your personal information is disclosed by us only as is necessary for such organizations to perform their contracted services, and for no other purpose.

TSG may also disclose your personal information:

For legal or regulatory compliance purposes including:

to exercise our legal rights or defend legal proceedings;

cooperating with law enforcement, regulatory or other government agencies;

as permitted by applicable laws and/or regulations; and

as required by a court order;

When we hold a reasonable belief that disclosure is required:

in order to investigate, prevent, or take action regarding actual or suspected illegal activity; and

to protect and defend TSG’s rights or property or safety of TSG, its customers, staff, suppliers or others.

TSG will not disclose personal information to others other than as set out in this Policy or as agreed to contractually by our customers or as otherwise consented to.

ACCESSING AND UPDATING YOUR PERSONAL INFORMATION

You have the right to request from us copies of or access to your personal information that we hold. Please contact us for further details. We may request payment of a small fee, as permitted under applicable law. If you believe that any information that we have about you is inaccurate or incomplete, please inform us as soon as possible.

DATA AGGREGATION AND ANONYMISATION

We may aggregate or anonymize your personal information in such a way as to ensure that you are not identified or identifiable from it, in order to use the anonymized or aggregated data. For example, for statistical analysis and administration including trend analysis, to design products and services and to analyze costs and charges in relation to our products and services, and to conduct risk assessment. We may share anonymized or aggregated data with our related companies and with other third parties. This policy does not restrict TSG's use or sharing of any non-personal, summarized, derived, anonymized or aggregated data.

COMMITMENT TO SECURITY, PRIVACY AND STANDARDS

We take our responsibility to protect the security and privacy of the personal information we hold seriously. We maintain administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Any suspected attempt to breach our policies and procedures, or to engage in any type of unauthorized action involving our information systems, is regarded as potential criminal activity. Such attempts and any other suspect behavior may be reported to the appropriate authorities.

Please remember that communications over the internet such as emails are not completely secure. We endeavor to keep secure all confidential information and personal information submitted to us through this website in accordance with our obligations under applicable laws and regulations. However, like all website operators, we cannot guarantee the security of any data transmitted through this website.

COOKIES

In providing this website, TSG utilizes "cookies". A cookie is a small text file that is stored on your computer for record-keeping purposes. A cookie does not identify you personally or contain any other information about you, but it does identify your computer.

We and some of our related companies and third-party service providers may use a combination of “persistent cookies” (cookies that remain on your hard drive for an extended period of time) and “session ID cookies” (cookies that expire when you close your browser) on the website to, for example, track overall site usage, and track and report on your use and interaction with ad impressions and ad services.

You can set your browser to notify you when you receive a cookie so that you will have an opportunity to either accept or reject it in each instance. However, you should note that refusing cookies may have a negative impact on the functionality and usability of the website.

We do not respond to or honor “Do Not Track” requests at this time.

EXTERNAL LINKS

TSG may provide links on this website to other websites that are not under our control. We do not endorse or make any warranty of any type regarding the content contained on such websites or products and services offered on those websites. We make no representation regarding your use of such websites. Please be aware that we are not responsible for the privacy practices of the operators of other websites. We encourage our users to be aware when they leave our site, and to read the privacy statements/policies of each and every website that collects personal information. This policy applies solely to information collected by us. You should read any other applicable privacy and cookies policies carefully before accessing and using such other websites.

MINORS

This Website is not intended for use by children. We do not solicit or knowingly accept any personal information from persons under the age of 18.

TSG COMPLAINTS PROCESS

If you wish to complain about how we have handled your personal information, please provide our Privacy Officer with full details of your complaint and any supporting documentation:

provide an initial response to your query or complaint within 10 business days, and

investigate and attempt to resolve your query or complaint within 30 business days or such longer period as is necessary and notified to you by our Privacy Officer.

If you are still not satisfied, you may have the lodging an official complaint with a Government agency. Please see the ‘Region-Specific Information’ section below.

REGION-SPECIFIC INFORMATION

Users in the following regions and countries should read the sections below, which contain additional information about regional-specific privacy laws and regulations. In the event of conflict between the information above and the sections below, the sections below will prevail for the regions and countries specified.

Users in the United Kingdom and other countries within the European Economic Area

Your personal information may be processed in countries outside the European Economic Area (EEA) which may not have data privacy laws equivalent to those in the EEA. This includes transfers between TSG and its related companies. The relevant Global Payments companies will take the necessary measures to ensure protection of your personal data collected through this website in accordance with applicable data privacy laws.

Either Harlands Services Limited or Debit Finance Collections PLC. (as applicable) as distributors of TSG in the European Union, will be responsible under applicable privacy laws to the extent they use your personal information for their own purposes. If TSG or any of its other related companies uses your personal information for its own purposes, that entity may also be responsible under any privacy laws applicable to it. You may contact either Harlands Services Limited or Debit Finance Collections PLC. to receive additional information about the third-parties to whom your personal data is shared as well as the legal basis for processing such data, and specific information about exercising your data subject rights under the General Data Protection Regulation (GDPR).

Australia

Under the Privacy Act 1988 (Cth) (the Australian Privacy Act), you have the right to:

request access to your personal information;

request the correction of your personal information; and

complain about a breach by us of the Australian Privacy Principles (in Schedule 1 of the Australian Privacy Act) or any binding registered APP Code.

We will handle any complaints or requests for access to or correction of personal information in accordance with our obligations under the Australian Privacy Act. All complaints are taken seriously and will be assessed by appropriate personnel with the aim of resolving any issue in a timely and efficient manner and in accordance with the Australian Privacy Act.

If you would like to lodge an official compliant, you can contact the Australian Information Commission:

TSG reserves the right to change this policy at any time, and any amended policy is effective upon posting to this website. We will make every effort to communicate any significant changes to you via email or other notification. Your continued use of our services and access of this website, will be deemed acceptance of any amended policy.